Privacy Policy

Last modified: September 01, 2017

Achiredo LLP respects your right to privacy. This Privacy Policy describes how we collect, use, store, disclose and protect your personal information in relation to the Achiredo electric bicycle Sharing Platform, including all related Achiredo websites and mobile applications, printed or electronic documentation, updates and support services (collectively, the “Achiredo electric bicycle Sharing Services”). We urge you to read the terms of this Privacy Policy carefully and, when prompted within the Achiredo electric bicycle Sharing Services, make selections involving your personal information that you deem appropriate based on the guidance of this Privacy Policy. Please note, if you do not provide certain information we request, all aspects of the Achiredo electric bicycle Sharing Services may not be available to you or may not function properly.

1.SCOPE AND CONSENT

1.1 By visiting, accessing or using the Achiredo electric bicycle Sharing or registering for an account, you expressly consent to the collection, use, storage, transfer, processing and disclosure of your information, including personal information, in accordance with this Privacy Policy. IF YOU DO NOT AGREE TO ANY TERM OF THIS PRIVACY POLICY, DO NOT ACCESS OR USE THE ACHIREDO ELECTRIC BICYCLE SHARING SERVICES OR REGISTER FOR AN ACCOUNT.

1.2 We reserve the right to modify this Privacy Policy from time to time, in our sole discretion, upon notice to you. We may give notice by making the updated Privacy Policy available through the Achiredo electric bicycle Sharing Services or by other reasonable means. The updated Privacy Policy is binding on you as of the effective date indicated at the top of the updated Privacy Policy. If you do not agree to the Privacy Policy or any update, please do not use the Achiredo electric bicycle Sharing Services. Your continued use of the Achiredo electric bicycle Sharing Services after the effective date of any update constitutes your acceptance of the updated Privacy Policy.

1.3 You are responsible for ensuring we have an up-to-date active and deliverable email address and phone number for you and periodically visiting this Privacy Policy to check for any changes.

2.INFORMATION COLLECTED

We collect personal information (which is information that can identify you, such as, for example, your name or email address) in the following ways:

2.1 Information You Provide

a)When registering for an account or accessing or using the Achiredo electric bicycle Sharing Services, including but not limited information about you such as your name, gender, date of birth, nationality, telephone number, email address, contact address, credit card numbers, bank account information, UIDAI number;

b)When using the Achiredo electric bicycle Sharing Services to share content with your families and friends or to invite others to use our services, including but not limited information about others that you invite or share content with;

c)When you fill in the forms and questionnaires or when you answer other questions we provide to you;

d)When you contact and communicate with us (e.g., by email, etc.), such as your name, email address and other contact information; and

e)When we authenticate or identify you or the information we have collected or we are otherwise required or authorized to collect by applicable laws.

2.2 Information We Collect Automatically

a)Similar to other websites and services, we automatically collect information about your interaction with the Achiredo electric bicycle Sharing Services such as your device type, device identity, unique identifier and IP address. For more information, please see “Information We Collect through Cookies, Web Beacons and Other Technologies” below;

b)We collect contact information stored in your mobile phone’s (or other mobile device’s) address book and store and synchronize the same in our cloud server when you turn on the Address Book Access or other services related to your address book. You may turn off the Address Book Access to disable the collection of additional contact information in your address book.

c)Location Information

i. Certain aspects of the Achiredo electric bicycle Sharing Services require us to obtain your location information, including GPS coordinates in real time (“Location Information”). For example, you may provide and we may collect Location Information, such as your region information contained in your account and the shared information showing your current or previous location uploaded by you or others. We may collect your Location Information through GPS, Wi-Fi and other means when you use the Achiredo electric bicycle Sharing Services;

ii.You may turn off the location feature to disable the further collection of your Location Information. However, please note that because your Location Information is vital to our knowledge of your safety and the condition of the shared electric bicycle you are using, if you disable collection of your Location Information, certain features of the Achiredo electric bicycle Sharing Services may not be available to your or may not function properly.

2.3 Information We Collect through Cookies, Web Beacons and Other Technologies

a)Similar to other websites and services, we collect certain information automatically through various mechanisms. This collection may include, but is not limited to: your IP address, browser type and language, device type, device identifiers, other device and software information (such as configuration information on your device and other applications), apps you access, search and browsing information, web usage information, referring/exit pages and URLs, other browser history, platform type, number of clicks, landing pages, cookie information, the pages you requested and viewed, the amount of time spent on particular pages and the date and time of each request you make. We collect this information in order to better understand our users, to more efficiently operate our business, to promote products and services (including those by third parties) and to improve the quality of the Achiredo electric bicycle Sharing Services. We may automatically collect information using various mechanisms, including, but not limited to, cookies and pixels.

I. Cookies. A cookie is a small text file that is stored on a computer for record-keeping purposes. Our third-party analytics/advertising providers use cookies to record information about your activities while using the Achiredo Electric bicycle Sharing Services and to “remember” you when you return to the Achiredo Electric bicycle Sharing Services. Some cookies remain on your computer until you delete them. Others, like session ID cookies, expire when you close your browser. You may set your browser setting to attempt to reject cookies and you may still use the Achiredo Electric bicycle Sharing Services, however, certain features of the Achiredo Electric bicycle Sharing Services may not be available if your browser does not accept cookies. See the section titled “Do Not Track Settings” below for more information on how the Achiredo Electric bicycle Sharing Services may respond to your browser settings. We do not control the use of cookies by third parties. Please also see the section titled “Third Party Analytics Providers” below.

II.Pixels (aka web beacons). Pixels are tiny graphics with a unique identifier that are used to track the online movements of web users. Unlike cookies, which are stored on a computer’s hard drive, pixels are small graphics that are about the size of the period at the end of the sentence that are embedded invisibly on web pages or in HTML-based emails. Our third-party analytics/advertising providers may place pixels in the Achiredo electric bicycle Sharing Services that track what other websites you visit (both before and after visiting the Site). Our third-party analytics providers use information obtained from pixels to help us improve our business and the Achiredo electric bicycle Sharing Services. We do not control the use of pixels by third parties.

b)Third Party Analytics Providers. We use third parties to help us operate and improve the Achiredo electric bicycle Sharing Services. In doing so, we may share with these third parties non-personally identifiable information about users’ use of the Achiredo electric bicycle Sharing Services. These third party providers also use cookies. We use third party analytics providers, such as Google Analytics, to provide us with general demographic and interest-level information about our users and to help create a better user experience. We may also make available to you third party content from other websites or applications, which may contain cookies and pixels. The collection and use of such information by these third parties are not bound by this Privacy Policy. We do not control information collected by third parties and we are not responsible for their use of that information.

c)Google Analytics uses cookies and pixels in order to collect demographic and interest-level information and usage information from users that visit the Achiredo electric bicycle Sharing Services, including, but not limited, to information about the pages where users enter and exit the Achiredo electric bicycle Sharing Services and what pages users view on the Achiredo electric bicycle Sharing Services, time spent, browser, operating system, device information and IP address. Cookies and pixels allow Google to recognize a user when a user visits the Achiredo electric bicycle Sharing Services and when the user visits other websites. Google uses the information it collects from the Achiredo electric bicycle Sharing Services and other websites to share with us and other website operators information about users including, but not limited to, age range, gender, geographic regions, general interests and details about devices used to visit websites and purchase items. We take reasonable measures to prevent linking information we receive from Google with any of your personally identifiable information. For more information regarding Google’s use of cookies and collection and use of information see the Google Privacy Policy. To opt out of Google Analytics, please visit the Google Analytics Opt-Out Page to learn about opting out and installing the appropriate browser add-on.

d)You may share our services or certain content by clicking the “Share” button or logging in to the Achiredo electric bicycle Sharing Services using the access service of third parties. These features may collect your log-in information and other personal information and may install cookies on your computer for the normal operation of the above features.

2.4 Using Third-Party Services and Visiting Third-Party Websites. We may collect information when you use your account to log into other websites or to use the Achiredo electric bicycle Sharing Services; when you browse web pages containing our plugins and cookies via third-party services; and when you use the websites and services of our partners

2.5 Payment Information; Third-Party Payment Processor. Online payments are handled through our third party payment processor. Our third party payment processor will collect and may retain your credit card information in order to process your payment. The credit card information that you provide is encrypted and transmitted directly to our payment processor. We do not store your credit card information and do not control and are not responsible for our payment processor or its collection or use of your information. You may find out more about how our payment processor stores and uses your credit card information by reviewing our payment processor’s Privacy Policy prior to submitting your payment information. Please also see the section titled “Affiliated Entities and Service Providers” below.

2.6 Information Collected from Other Channels. We may collect information in other ways permitted by law or as otherwise described to you at the time of collection.

3.INFORMATION USE AND RETENTION

3.1

a) To Provide and Improve our Services

i.To operate the Achiredo electric bicycle Sharing Services and provide them to you, including but not limited use of push notifications to your device and making targeted responses to your personalized requests such as language settings, location settings, personalized help services, and instructions or to respond in other aspects to you and other users.

ii.For identity authentication, customer service, safety precaution, fraud monitoring, archiving and backup to ensure the safety of the products and services provided by us to you through the Achiredo electric bicycle Sharing Services.

iii.To assist us in creating, developing, improving, and securing products, services, content and preventing the loss or leaking of data or information.

iv.To communicate with you, including but not limited to sending you important notices, such as services-related information, modifications to terms, conditions and rules, system maintenance notices, software certifications and software upgrades.

v.For internal purposes such as auditing, data analysis and research.

vi.To aggregate or personalize the information collected through a particular service for use of the same in our other services in accordance with applicable laws and regulations, for example, the information collected when you use one of our services may be used to provide certain content to you in another service or to show you other related information. You may also authorize us to use the information provided and stored via one service for our other services if we provide such option in the relevant service.

b) For Promotion, Advertising, and Marketing

i)To promote and advertise products, services, and content (including those offered by us and third parties), including both offline and online (e.g., via email, telephone, text message, postal mail, and social networks such a WeChat, Weibo, Facebook, Instagram, Snapchat, Twitter and WhatsApp) and to evaluate the effect of advertising and promotional activities.

ii)If you do not wish to receive advertisements or promotional information, you may opt out by following our instructions on any non-service related communications. Even if you opt out, you will continue to receive service-related communications from us.

c) To Conduct Polls and Questionnaire Surveys. To invite you to participate in polls and questionnaire surveys conducted by us or in collaboration with third parties.

d) To Enhance Safety Safeguards. To resolve disputes, prevent, detect, handle and investigate fraudulent or other illegal activities; to mitigate the risks of the occurrence of similar events; to assist law enforcement; and to enforce this Privacy Policy.

3.2 We may use non-personally identifiable information and aggregate information and share it with third parties for any lawful purpose, including, but not limited to, analyzing trends, managing and administering the Achiredo electric bicycle Sharing Services, tracking users’ movements, to create new products or services or to improve our business and the Achiredo electric bicycle Sharing Services.

4.INFORMATION DISCLOSURE, PROCESSING AND TRANSMISSION

4.1 Disclosure. We may disclose personal information to third parties as follows:

a)We may share your personal information with our affiliates, partners, companies we do business with, service providers, contractors and agents (such as the communication service providers sending e-mails or notifications on behalf of us or the service providers providing location data for us) for any of the purposes outlined in Section 3. Any disclosure under this paragraph will be made subject to third parties that agree only to use the information as permitted under this Privacy Policy.

b)To provide information to other users as authorized or agreed by you.

c)To comply with applicable laws and regulations, court orders or rulings in other legal proceedings, or the requirements of relevant governmental agencies or authorities.

d)To protect our rights, property or safety (including those of other users or employees).

e)In connection with any actual or potential merger, acquisition, asset sale or other similar transaction involving us or our affiliates.

d)If we or our affiliate(s) file for bankruptcy.

4.2 Processing; Transmission

We may use various technologies to process your personal information within the scope allowed by this Privacy Policy. We may transmit your personal information to countries or regions outside your country or region of residence. You understand and agree that we and third parties may, in providing the Achiredo Electric Bicycle Sharing Services to you and in disclosing information to third parties as permitted under this Privacy Policy, store and processes personal information in different locations all around the world.

5.SECURITY

5.1 We use various security technologies and programs designed to prevent the loss, improper use, unauthorized browsing or disclosure of your personal information. For example, we will store your personal information in a system with access authorization settings and install the system in a device with access authorization settings. However, for the sites you log into, it is your responsibility to ensure the safekeeping of your passwords and not to disclose such information to others.

5.2 When you use the Achiredo Electric Bicycle Sharing Services, some of your personal information and content you upload or share may be viewed by other users (e.g., if you share your riding track and your personal information from the Achiredo Electric Bicycle Sharing Services on the platforms of third parties) and users may read, collect or use your personal information and share it with others. You are responsible for the personal information you decide to share or submit in the using these features. Please be careful when using upload and sharing features and carefully consider the content you upload and communicate through the Achiredo Electric Bicycle Sharing Services.

5.3 Despite our implementation of security technologies, we cannot ensure that all of your personal information will never be disclosed in ways not otherwise described in this Privacy Policy. For example, no transmission of data over the internet is 100% secure and a third party may unlawfully intercept or access transmissions or private communications, or other users of the Achiredo Electric Bicycle Sharing Services may abuse or misuse your personal information. You fully understand and agree to accept the risks of unauthorized access, use and disclosure of your personal information that may occur despite our compliance with this Privacy Policy and implementation of security technologies.

6.CUSTOMIZATION OPTIONS

1 “Do Not Track” Settings. Because we track Achiredo Electric Bicycle Sharing Services usage information through the use of cookies, pixels, and other tracking mechanisms, your selection of the “Do Not Track” option provided by your browser may not have any effect on our collection of cookie information. The only way to completely “opt out” of the collection of any information through cookies, pixels, or other tracking technology is to actively manage the settings on your browser to delete and disable cookies and other tracking/recording tools. However, getting a “Do Not Track” signal to work as you might want is difficult. Using browsers as an example, not all tracking technologies can be controlled by browsers; unique aspects of your browser might be recognizable even if you disable a tracking technology; not all settings will necessarily last or be effective; even if a setting is effective for one purpose, data still may be collected for another; and even if one website observes a “Do Not Track” signal, that website usually will not be able to control other websites. Please be aware that if you disable cookies or pixels, you may not be able to enjoy the full experience and some services may not work properly

2 Through the Achiredo Electric Bicycle Sharing Services, you may, in accordance with this Privacy Policy:

a.Review and update your personal information and close your account;

b.For certain communications, determine the types of information and the manners by which you will receive them; and

c.Opt out of participating in promotional programs.

3. Correcting your Personal Information. You may correct your personal information by contacting us at: achirdeo@gmail.com. We will make good faith efforts to resolve requests to correct inaccurate information except where the request is unreasonable, requires disproportionate technical effort or expense, jeopardizes the privacy of others or would be impractical.

7.TERMINATION, RETENTION, AND REMOVAL

1 Termination. If your account is terminated for any reason, your information will no longer be accessible to you. However, information collected prior to termination of your account may still continue to be retained in accordance with this Privacy Policy

2 Retention and Removal. We may, but are not required to retain your personal information, including after your account is terminated, for as long as permitted under applicable law. If you want to us to remove your information from the Achiredo Electric Bicycle Sharing Services, please contact our customer service staff at achirdeo@gmail.com and we will make good faith efforts to delete information stored in systems under our control provided that removal does not require disproportionate technical effort or expense, does not jeopardizes the privacy of others, and is not impractical.

8.YOUR OBLIGATIONS

1 You agree to properly safeguard your account number and login password;

2 You agree that only you personally can use the account created in your name and you will not allow others to use your account or share one common account with others

9.Contact Us

If you would like us to update information we have about you or if you have any questions or comments about this Privacy Notice, please contact us by email at achirdeo@gmail.com  subject line Privacy Policy. You also may write to us at:

902-Tower 3,

Takshila Heights,

Sector 37 C Gurugram, Haryana